NL-15-025, Fourth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Fourth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML15069A028
Person / Time
Site:	Indian Point
Issue date:	02/27/2015
From:	Coyle L Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-025, TAC MF0744, TAC MF0745
Download: ML15069A028 (25)

Text

Entergy Nuclear Northeast Indian Point Energy Center SEntergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-025 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, OWFN-2 FL Rockville, MD 20852-2738

SUBJECT:

Indian Point Energy Center's Fourth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745)

Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0, dated August 2012

4. Entergy letter to NRC (NL-12-144), Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated October 29, 2012

5. Entergy letter to NRC (NL-1 3-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2013

6. Entergy letter to NRC (NL-1 3-110), Indian Point Energy Center's First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2013 a

NL-15-025 Dockets 50-247 and 50-286 Page 2 of 3 (ML13247A032) 7 Entergy letter to NRC (NL-14-031), Indian Point Energy Center's Second Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated February 27, 2014 (ML14070A365) 8 Entergy letter to NRC (NL-14-110), Indian Point Energy Center's Third Six-Month Status Report for the Implementation of Order EA-1 2-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2014 (ML14251A227)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Entergy initial status report regarding mitigation strategies.

Reference 5 provided the Entergy overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided the first six-month status report.

Reference 7 provided the second six-month status report. Reference 8 provided the third six-month status report. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

NL-15-025 Dockets 50-247 and 50-286 Page 3 of 3 I declare u,,der penalty of perjury that the foregoing is true and correct; executed on February -C* 2015.

Sincerely,

Attachment:

Indian Point Energy Center's Fourth Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 Mr. John Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspectors Office Mr. John B. Rhodes, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Mr. Robert J. Fretz Jr., NRC NRR OE OB Mr. Robert L. Dennig, NRC NRR DSS SCVB Ms. Jessica A. Kratchman NRC NSIR DPR DDEP IRIB Mr. Eric E. Bowman, NRC NRR DPR PGCB Ms. Eileen M. Mckenna, NRC NRO DSRA BPTS NRC NRR DSS SCVB

ATTACHMENT TO NL-15-025 INDIAN POINT ENERGY CENTER'S FOURTH SIX-MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-049 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 1 of 21 Indian Point Energy Center's Fourth Six Month Status Report for the Implementation of Order EA-12-049 Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Entergy Nuclear Operations, Inc. (Entergy) developed an Overall Integrated Plan (Reference 1) for Indian Point Energy Center (IPEC), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the last status report (Reference 5), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since July 31, 2014, and are current as of January 31, 2015:

• Third Six-Month Status Report - August 2014

• IPEC-3 Training, Develop Training Plan - September 2014

• Perform Staffing Analysis - November 2014

• IPEC-3 On-Site FLEX Equipment, Purchase / Procure - January 2015

• IPEC-3 Procedures, Create Indian Point FSGs - January 2015

• Fourth Six-Month Status Report - Complete with submission of this document in February 2015 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. The milestone listing includes Unit 2 and Unit 3 sections for unit specific milestones.

These new milestone target completion dates do not impact the Order implementation date.

Target Revised Target Milestone Completion Activity Status Completion Date* Date Submit Overall Integrated Feb 2013 Complete Implementation Plan Submit Six Month Updates Update 1 Aug 2013 Complete

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 2 of 21 Target Revised Target Milestone Completion Activity Status Completion Date* Date Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Perform Staffing Analysis Nov 2014 Complete Off-site FLEX Equipment Develop Strategies with NSRC Oct 2015 Started Procedures PWROG issues NSSS-specific Jan 2014 Complete Issued guidelines May 2013 Validation / Demonstration May 2016 Started Submit Completion Report Spring 2015 Not Started See Section 5 IPEC Unit 3 Submit Completion Report Jun 2016 Not Started IPEC Unit 2 Unit 2 Specific Milestones Modifications Engineering and Implementation N-1 Walkdown (Unit 2) Spring 2014 Completed Design Engineering Dec 2014 Started June 2015 Unit 2 Implementation Outage Apr 2016 Not Started On-site FLEX Equipment Purchase / Procure Dec 2015 Started Off-site FLEX Equipment Develop Strategies with NSRC Oct 2015 Started Procedures Create Indian Point FSG Oct 2015 Started May 2015 Create Maintenance Oct 2015 Not Started Procedures Training:

Develop Training Plan Aug 2015 Not Started

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 3 of 21 Target Revised Target Milestone Completion Activity Status Completion Date* Date Implement Training April 2016 Not Started Unit 3 Specific Milestones Modifications Engineering and Implementation N-1 Walkdown (Unit 3) Spring 2014 Completed Design Engineering Dec 2014 Completed Unit 3 Implementation Outage Apr 2015 Not Started On-site FLEX Equipment Purchase / Procure Dec 2014 Completed Jan 2015 Procedures Create Indian Point FSG Oct 2014 Completed Create Maintenance Procedures Oct 2014 Started April 2015 Training:

Develop Training Plan Nov 2014 Completed Implement Training Apr 2015 Started March 2015

• - Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month status reports 4 Changes to Compliance Method In the continuing design development phase of the FLEX project at IPEC, changes have been identified to the compliance strategies as described in the original OIP (Reference 1).

• Indian Point Energy Center will implement PWROG-14027 (Reference 10) time to reflux cooling mass balance methodology. The implementation of this methodology will apply site specific initial Reactor Coolant System (RCS) mass and Accumulator injected mass, and the 4-loop reference plant RCS mass at the time to enter reflux cooling. RCS makeup will be operational prior to the calculated time to reflux cooling of 11.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for IP2, and 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> for IP3.

• On Page 44 of the OIP, it is stated, "Additional equipment may be required to be powered during this event such as portable lighting and ventilation fans. These are not conveniently powered via the FLEX generator." For IPEC Unit 2 the current strategy is to restore ventilation to the control room with the Phase 2 portable generator. For the battery room, the current strategy is to stage a portable blower and a duct to dilute/disperse the hydrogen within four hours of beginning battery charging operations.

• Lighting panels for high priority areas (e.g., control building, control room, some Primary Auxiliary Building, Turbine Building, and Turbine Auxiliary Boiler

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 4 of 21 Feedwater Pump room) can, in most cases, be repowered by the Phase 2 portable generator.

• Nitrogen bottles are being added to the FLEX Equipment Storage Building to ensure 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of nitrogen is available for the Atmospheric Dump Valves (ADVs).

" Modifications are being implemented to ensure adequate nitrogen is available to the City Water Supply Valve (PCV-1 188) to allow the alignment of the City Water Storage Tank to the suction of the Turbine Driven Auxiliary Boiler Feedwater Pump (TDABFP).

• New Seal Leakoff rates per PWROG-14015 Category 1 plants are being implemented that will change integrated leakage volumes and associated reflux cooling timelines.

• Modifications to the #1 Seal Leakoff Lines to install orifices will be implemented to enable using PWROG-14015 Category 1 leakage rates.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation IPEC expects to comply with the order implementation date for IPEC Unit 2, however, as part of a separate submittal (Reference 8) Entergy has requested an extension for IPEC Unit 3 for no later than startup of refueling outage (3R19) in spring 2017. Entergy is currently planning to install an orifice on the seal leak off line during refueling outage 3R18 (spring 2015) that would align the leakage rates with the leakage rates for Category 1 plants as provided on Table 6 of PWROG-14015 (Reference 9). The requested relaxation will not be required if implementation of Order EA-12-049 is achieved with the successful completion of the modification. If this modification is not completed during 3R18, the relaxation would be required to allow Entergy to license and implement the approach used to bring IPEC Unit 3 into compliance during 3R19.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary and status of any open items documented in the Overall Integrated Plan and any open items or confirmatory items documented in the Interim Staff Evaluation (ISE). A fourth table includes the FLEX related NRC Audit Visit Open Items, which includes open items on previously issued Audit Questions and new Safety Evaluation (SE) Open Items that were not closed during the October 2014 NRC Audit Visit as documented in the NRCs Report for the Onsite Audit (Reference 7). A fifth table includes a listing of all Audit Questions and the status of each item.

Overall Integrated Plan Open Item Status There were no open items documented in the IPEC Overall N/A Integrated Plan

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 5 of 21 Interim Staff Evaluation Open Items Status 3.1.2.A Review of the licensee's new flooding level This item was closed evaluation results and its potential impact on the during the October 2014 flooding hazard analyses previously provided in NRC Audit Visit their Integrated Plan and during the audit (associated with AQ process is identified as an Open Item. If the IPEC-.006) flooding levels are modified based on the results of this review, it may affect the evaluation of the deployment described in Section 3.1.2.2 of this evaluation.

3.2.4.7.A It is noted that NEI 12-06 guidance only credits This item was closed water supplies that are robust with respect to during the October 2014 seismic events, floods, and high winds, and the NRC Audit Visit associated missiles. The licensee should (associated with AQ determine if a water supply for the SGs and IPEC-041).

RCS would be available after a tornado event by analyzing the tornado characteristics for the site compared to the separation characteristics of the tanks. This is an alternate approach from the strategies identified in NEI 12-06.

Interim Staff Evaluation Confirmatory Items Status 3.1.1.2.A Confirm that at least one connection point for For Unit 2 this item is the FLEX AFW pump is accessible and is addressed by updated located inside a building that is seismically AQ IPEC-036 response.

robust as described in Consideration 2 of NEI For Unit 3, this item was 12-06, Section 5.3.2. closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-036).

3.1.1.2.B Confirm that the pickup trucks, forklifts or any This item was closed other equipment that will be used to deploy the during the October 2014 portable equipment for implementing FLEX NRC Audit Visit.

strategies will be reasonably protected from the event as described in Consideration 5 of NEI 12-06, Section 5.3.2.

3.1.1.2.C Confirm provisions will be made to ensure that This item is addressed by access to all required areas will be assured in updated AQ-IPEC-023 the event of a power failure as described in response.

Consideration 5 of NEI 12-06, Section 5.3.2.

3.1.1.2.D Confirm that the licensee has reviewed the This item was closed deployment paths from the near site storage during the October 2014 areas to the site and from the onsite storage NRC Audit Visit

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 6 of 21 Interim Staff Evaluation Confirmatory Items Status areas to the deployment location to verify that (associated with AQ these paths are not subject to soil liquefaction IPEC-002).

concerns as described in Consideration 1 of NEI 12-06, Section 5.3.2.

3.1.1.3.A Confirm that the licensee's review of the For Unit 2, this item is potential impacts of large internal flooding addressed by updated sources that are not seismically robust and do AQ IPEC-004 response.

not require ac power has been completed per For Unit 3, this item was consideration 2 of NEI 12-06, Section 5.3.3. closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-004).

3.1.1.4.A Confirm that the intermediate staging area has This item was closed been selected and implementing procedures during the October 2014 have been developed. NRC Audit Visit (associated with AQ IPEC-005).

3.1.2.2.A Confirm that evaluations address: whether This item was closed procedures have been established for actions to during the October 2014 be taken upon receipt of a hurricane warning; NRC Audit Visit ensuring that fuel in oil storage tanks would not (associated with AQ be inundated or damaged by flooding; and, IPEC-006).

whether the means (e.g., trucks) for moving FLEX equipment is reasonably protected from the event.

3.2.1.A Confirm which analysis performed in WCAP- This item was closed 17601-P is being applied to Indian Point. Also following the October confirm the licensee has adequately justified the 2014 NRC Audit Visit as use of that analysis by identifying and documented in evaluating the important parameters and Reference 7 (associated assumptions demonstrating that they are with AQ IPEC-012).

representative of Indian Point and appropriate for simulating the ELAP transient.

3.2.1.1 .A Confirm that the licensee is using NOTRUMP This item was closed and has taken into account its limitations, following the October Reliance on the NOTRUMP code for the ELAP 2014 NRC Audit Visit as analysis of Westinghouse plants is limited to the documented in flow conditions prior to reflux condensation Reference 7 (associated initiation. This includes specifying an acceptable with AQ IPEC-012).

definition for reflux condensation cooling.

3.2.1.3.A Confirm that the licensee has satisfactorily This item was closed addressed the applicability of Assumption 4 on during the October 2014 page 4-13 of WCAP-1 7601 which states that NRC Audit Visit

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 7 of 21 Interim Staff Evaluation Confirmatory Items Status decay heat is per ANS 5.1-1979 + 2 sigma, or (associated with AQ equivalent. If the ANS 5.1-1979 + 2 sigma IPEC-013).

model is used in the Indian Point ELAP analysis, address the adequacy of the use of the decay heat model in terms of the plant-specific values of the following key parameters:

(1) initial power level, (2) fuel enrichment, (3) fuel burnup, (4) effective full power operating days per fuel cycle, (5) number of fuel cycles, if hybrid fuels are used in the core, and (6) fuel characteristics (addressing whether they are based on the beginning of the cycle, middle of the cycle, or end of the cycle). If a different decay heat model is used, describe the specific model and address the adequacy of the model and the analytical results.

3.2.1.6.A Confirm that the licensee has finalized its For Unit 2, this item is strategy for controlling the RCS pressure to addressed by updated prevent nitrogen from escaping from the safety AQ IPEC-035 response.

injection accumulators into the RCS until the For Unit 3, this item was isolation valves can be closed, closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-035).

3.2.1.8.A The PWROG submitted to NRC a position This item is addressed by paper, dated August 15, 2013, which provides updated AQ IPEC-050 test data regarding boric acid mixing under response.

single-phase natural circulation conditions and outlined applicability conditions intended to ensure that boric acid addition and mixing would occur under conditions similar to those for which boric acid mixing data is available. During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above. The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.

3.2.1.9.A Confirm that the licensee has specified the This item is addressed by required time for the operator to realign each of updated AQ IPEC-017 the above discussed pumps and confirm that response.

the required times are consistent with the results of the ELAP analysis. Confirm that the licensee discussed the analyses that are used to determine the required flow rate and corresponding total developed head for each of

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 8 of 21 Interim Staff Evaluation Confirmatory Items Status the portable pumps and also to justify that that the required capacities of each of the above-discussed portable pumps are adequate to maintain core cooling and sub-criticality during phases 2 and 3 of ELAP. Confirm that the licensee has included a discussion and justification of computer codes/methods and assumptions used in the analyses above.

3.2.1.9.B Confirm that the licensee has provided an For Unit 2, this item is evaluation that demonstrates flow through a 2- addressed by updated inch connection will be sufficient to provide AQ IPEC-036 response.

adequate flow to maintain the SG level using For Unit 3, this item was the alternate SG FLEX pump. closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-036).

3.2.2.A Confirm that the licensee has satisfactorily For Unit 2, this item is explained the strategy to provide a secondary addressed by updated connection for SFP makeup if the building is AQ IPEC-034 response.

inaccessible, and explain where these valves For Unit 3, this item was are and if access to these valves will be closed during the available during an ELAP event. October 2014 NRC Audit Visit (associated with AQ IPEC-034).

3.2.3.A Confirm that a containment evaluation has been This item is addressed by completed and, based on the results of this updated AQ response evaluation; required actions to ensure spreadsheet on the maintenance of containment integrity and ePortal. (Unit 3 Open required instrument function will be developed. Item from the October 2014 NRC Audit Visit.)

3.2.4.2.A Confirm that the assessment of the predicted This item is addressed by maximum temperatures in rooms with updated AQ IPEC-020 equipment that is required for FLEX strategies response. (Unit 3 Open during the ELAP demonstrates that the Item from the October equipment will continue to function as needed. 2014 NRC Audit Visit.)

3.2.4.2.8 Confirm that hydrogen concentration in the For Unit 2, this item is battery rooms during battery recharging would addressed by updated be maintained at an acceptable level. AQ IPEC-047 response.

For Unit 3, this item was closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-047).

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 9 of 21 Interim Staff Evaluation Confirmatory Items Status 3.2.4.3.A Confirm that the need for heat tracing has been This item is addressed by evaluated for the BAST and all other equipment updated AQ IPEC-021 necessary to ensure that all FLEX strategies response. (Unit 3 Open can be implemented successfully. Item from the October 2014 NRC Audit Visit.)

3.2.4.6.A Confirm that habitability limits will be maintained For Unit 2, this item is and/or operator protective measures will be addressed by updated employed in all Phases of an ELAP to ensure AQ IPEC-020 response.

operators will be capable of FLEX strategy For Unit 3, this item was execution under adverse temperature closed during the conditions. Examples of areas of concern are October 2014 NRC Audit the control room, TDABFW pump room, SFP Visit (associated with AQ area, and charging pump room. IPEC-020).

3.2.4.7.B Confirm that the licensee has evaluated the This item was closed acceptability of the missile protection for the during the October 2014 Unit 2 BAST. NRC Audit Visit (associated with AQ IPEC-041).

3.2.4.9.A Confirm that method for supplying fuel oil has For Unit 2, this item is been finalized. Also confirm that the fuel addressed by updated required for each FLEX piece of equipment has AQ IPEC-025 response.

been established and that the total fuel usage For Unit 3, this item was has been calculated to demonstrate that closed during the sufficient fuel with margin exists on site. October 2014 NRC Audit Visit (associated with AQ IPEC-025).

3.2.4.10.A Confirm that analysis of the following aspects of For Unit 2, this item is the dc power requirements have been identified addressed by updated and evaluated: AQ IPEC-026 response.

a. The dc load profile with the required loads For Unit 3, this item was for the mitigating strategies to maintain closed during the core cooling, containment, and spent fuel October 2014 NRC Audit pool cooling; Visit (associated with AQ

b. The loads that will be shed from the dc IPEC-026).

bus, the equipment location (or location where the required action needs to be taken), and the required operator actions and the time to complete each action

c. The basis for the minimum dc bus voltage that is required to ensure proper operation of all required electrical equipment.

3.4.A Confirm that the 480V portable/FLEX For Unit 2, this item is generators are adequately sized to supply loads addressed by updated

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 10 of 21 Interim Staff Evaluation Confirmatory Items Status assumed for implementing Phase 2 strategies. AQ IPEC-031 response.

For Unit 3, this item was closed during the October 2014 NRC Audit Visit (associated with AQ IPEC-031).

October 2014 NRC Audit Visit FLEX Related Open Items (Reference 7)

Audit Item Licensee Input Rfrne Reference Item Description NeddStatus Needed ISE Cl 3.2.3.A Containment Evaluation The calculation of the This item is The calculation of the conditions inside the addressed on conditions inside the containment building updated AQ containment building was done by the response was done by the licensee with an spreadsheet on licensee with an assumption of an initial the ePortal.

assumption of an initial leak rate of 21 gallons leak rate of 21 gallons per minute (gpm) seal per minute (gpm) seal leakage per RCP. As leakage per RCP. As the RCP seal leakage the RCP seal leakage model has not been model has not been accepted yet by the accepted yet by the NRC staff, it is not NRC staff, it is not possible to perform a possible to perform a final evaluation of this final evaluation of this calculation.

calculation.

ISE Cl Room Temperatures The staff requested the This item is 3.2.4.2.A The NRC staff needs licensee to provide addressed by additional information electrical equipment updated AQ on the maximum qualification for the IPEC-020 predicted temperatures temperatures reached in response on the in rooms where FLEX the control room and ePortal.

equipment is operating, TDAFW pump room.

and the equipment temperature limits, to confirm that there is no impact on equipment operation.

ISE CI Heat Tracing The NRC staff needs This item is 3.2.4.3.A The NRC staff needs additional information addressed by additional information on the ability to use updated AQ

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 11 of 21 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 7)

AuditRfrne Item Item Description Licensee Input NeddStatus Reference Needed on the ability to use outdoor tanks during IPEC-021 outdoor tanks during extreme cold conditions response on the extreme cold conditions with no operational heat ePortal.

with no operational heat tracing, especially when tracing. the use of the tank is delayed while FLEX equipment is deployed, and outdoor isolation valves must be opened.

AQ-27 Maintenance and The NRC staff has This item is Testing of FLEX concerns that testing addressed by Equipment procedures may not updated AQ The NRC staff has have sufficient details, IPEC-027 concerns that testing such as acceptance response on the procedures may not criteria and shelf-life ePortal.

have sufficient details, considerations for FLEX such as acceptance equipment, to identify criteria and shelf-life when FLEX equipment considerations for FLEX needs to be repaired or equipment, to identify replaced. Also, the when FLEX equipment licensee plans to extend needs to be repaired or certain intervals replaced. Also, the between testing longer licensee plans to extend than stated in the EPRI certain intervals templates endorsed by between testing longer the NRC. The licensee than stated in the EPRI will provide a report templates endorsed by which evaluates this the NRC. The licensee extension.

will provide a report which evaluates this extension.

AQ-28 Offsite Resources The NRC staff identified This item is The NRC staff identified that a revision is needed addressed by that a revision is needed to procedure FSG-1 00 updated AQ to procedure FSG-100 in order for the licensee IPEC-028 in order for the licensee staff to reach the step to response on the staff to reach the step to activate the offsite ePortal.

activate the offsite resource delivery. The resource delivery. The licensee also needs to licensee also needs to finalize the SAFER finalize the SAFER Response Plan for Response Plan for Indian Point, and

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 12 of 21 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 7)

AuditRfrne Item Item Description Licensee Input NeddStatus Reference Needed Indian Point, and finalize contractual finalize contractual arrangements for the arrangements for the use of the offsite staging use of the offsite staging areas.

areas.

AQ-46 Battery Room The NRC staff This item is Temperature Extremes requested the licensee addressed by The NRC staff needs to provide a technical updated AQ additional information to basis to support the IPEC-046 evaluate the conclusion that the response on the performance of the plant battery rooms would not ePortal.

batteries considering exposed to extreme the temperature high and low extremes (hot and cold) temperatures during the that may be reached in first phase of the ELAP the battery rooms. event.

AQ-51 Use of Non-Safety- The NRC staff This item is Related Equipment requested the licensee addressed by The NRC staff needs to address non-safety updated AQ information on the use related installed IPEC-051 of non-safety-related electrical equipment response on the installed electrical credited for mitigation ePortal.

equipment credited strategies and whether during an ELAP event this equipment will and its ability to perform survive the BDBEE.

its safety function considering the potential external hazards.

SE#2 RCP Seal Leakage and Provide final resolution This item is NSAL 14-1 for this issue. addressed on Westinghouse nuclear updated AQ safety advisory letter response NSAL 1 indicates spreadsheet on there may be higher the ePortal.

leakage from the reactor coolant pump (RCP) seals during an extended loss of ac power (ELAP) than was previously analyzed.

The licensee proposed to limit leakage by

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 13 of 21 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 7)

Audit Item [ i Licensee Input S Reference Item Description Neededaus throttling existing valves in the #1 seal leakoff line. The NRC staff expressed concerns regarding the licensee's proposal. The licensee is working to resolve this issue, and is considering modifications to the plant. The NRC will review the final resolution.

SE #5 Accuracy of the Provide PWROG This item is NOTRUMP Computer resolution on accuracy addressed on Code of the NOTRUMP code. updated AQ Westinghouse used the Provide a comparison response NOTRUMP computer chart to compare how spreadsheet on code to develop certain the plant parameters the ePortal.

timelines for operator assumed in the actions in an ELAP Westinghouse analyses event (see WCAP- compare to Indian Point 17601-P for example). parameters.

NRC simulations using the TRACE code indicate some differences, which may be significant enough to affect the timeline for operator actions. The Pressurized Water Reactor Owners Group (PWROG) is working with the NRC on a resolution, which may be applicable to all PWRs. The NRC staff also needs a comparison chart from the licensee to compare how the plant parameters assumed in the Westinqhouse

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 14 of 21 October 2014 NRC Audit Visit FLEX Related Open Items (Reference 7)

AuditRfrne Item Item Description Licensee Input NeddStatus Reference Needed analyses compare to Indian Point parameters.

SE #7 Operation of the SG The NRC staff has This item is ADVs concerns with the addressed on The NRC staff has nitrogen bottles used to updated AQ concerns with the provide the motive force response nitrogen bottles used to to operate the SG spreadsheet on provide the motive force ADVs, needed for plant the ePortal.

to operate the SG cooldown. Provide ADVs, needed for plant additional information cooldown. The staff on the capacity of the needs additional nitrogen bottles, and information on the what other equipment capacity of the nitrogen uses those bottles.

bottles, and what other equipment uses those bottles.

SE #13 RCP Seal Leakage The NRC staff needs This item is Rates information to addressed on The NRC staff needs demonstrate that the updated AQ information to current RCP seal response demonstrate that the leakage rate calculation spreadsheet on current RCP seal is accurate or the ePortal.

leakage rate calculation conservative.

is accurate or conservative.

SE #14 Pressurization of the The NRC staff has This item is RCP #1 Seal Leakoff asked the licensee to addressed on Line determine the expected updated AQ The NRC staff has maximum pressure in response asked the licensee to the #1 seal leakoff line spreadsheet on determine the expected during this event and to the ePortal.

maximum pressure in demonstrate that the the #1 seal leakoff line components of this line during this event and to will not fail in such a demonstrate that the manner that will components of this line increase the seal will not fail in such a leakage.

manner that will increase the seal leakage.

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 15 of 21 Audit Status Completion or Questions Target Date This item was closed during the October 2014 NRC IPEC-002 Audit Visit (associated with ISE Confirmatory Item Closed 3.1.1.2.D)

IPEC-003 This item was closed during the October 2014 NRC Closed Audit Visit.

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-004 Confirmatory Item 3.1.1.3.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.1.1.3.A)

This item was closed during the October 2014 NRC Closed IPEC-005 Audit Visit (associated with ISE Confirmatory Item 3.1.1.4.A)

This item was closed during the October 2014 NRC Closed IPEC-006 Audit Visit (associated with ISE Open Item 3.1.2.A and ISE Confirmatory Item 3.1.2.2.A)

This item was closed during the October 2014 NRC Closed Audit Visit.

This item was closed during the October 2014 NRC Closed Audit Visit.

IPEC-010 Updated response available on the ePortal Review ready IPEC-01 1 Updated response available on the ePortal Review ready This item was closed during the October 2014 NRC Closed IPEC-012 Audit Visit (associated with ISE Confirmatory Item 3.2.1.A and ISE Confirmatory Item 3.2.1.1.A)

This item was closed during the October 2014 NRC Closed IPEC-013 Audit Visit (associated with ISE Confirmatory Item 3.2.1.3.A)

This item was closed during the October 2014 NRC Closed Audit Visit. Closed IPEC-017 Updated response available on the ePortal (associated Review ready with ISE Confirmatory Item 3.2.1.9.A)

IPEC Unit 3 - Updated response available on the Review ready IPEC-020 ePortal (associated with ISE Confirmatory Item 3.2.4.2.A) (Unit 3 Open Item from the October 2014

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 16 of 21 Audit Status Completion or Questions Target Date NRC Audit Visit.)

IPEC Unit 2 Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.2.A)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE Confirmatory Item 3.2.4.6.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.6.A)

IPEC Unit 3 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.3.A) (Unit 3 Open Item from the October 2014 IPEC-021 NRC Audit Visit.)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.3.A)

This item was closed during the October 2014 NRC Closed Audit Visit.

Pdated available on the ePortal (associated with ISE Review ready confirmatory Item 3.1.1.2.C)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-025 Confirmatory Item 3.2.4.9.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.9.A)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-026 Confirmatory Item 3.2.4.10.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (ISE Confirmatory Item 3.2.4.10.A)

IPEC-027 Updated response available on the ePortal (Unit 3 Review ready Open Item from the October 2014 NRC Audit Visit.)

IPEC-028 Response available on the ePortal (Unit 3 Open Item Review ready from the October 2014 NRC Audit Visit.)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 17 of 21 Audit Status Completion or Questions Target Date IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-031 Confirmatory Item 3.4.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.4.A)

IPEC-032 This item was closed during the October 2014 NRC Closed Audit Visit.

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

IPEC-033 IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-034 Confirmatory Item 3.2.2.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal(associated with ISE Confirmatory Item 3.2.2.A)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-035 Confirmatory Item 3.2.1.6.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.1.6.A)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE Confirmatory Item 3.1.1.2.A)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item IPEC-036 3.1.1.2.A)

IPEC Unit 3 - This item was closed during the October 2014 NRC Audit Visit (associated with ISE Closed Confirmatory Item 3.2.1.9.B)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.1.9.B)

This item was closed during the October 2014 NRC Closed Audit Visit.

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 18 of 21 Audit Status Completion or Questions Target Date This item was closed during the October 2014 NRC Closed IPEC-041 Audit Visit (associated with ISE Open Item 3.2.4.7.A and ISE Confirmatory Item 3.2.4.7.8)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

IPEC-042 IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

IPEC-043 IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

IPEC-045 IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - Updated response available on the Review ready ePortal (Unit 3 Open Item from the October 2014 NRC IPEC-046 Audit Visit.)

IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit (associated with ISE IPEC-047 Confirmatory Item 3.2.4.2.B)

IPEC Unit 2 - Updated response available on the Review ready ePortal (associated with ISE Confirmatory Item 3.2.4.2.B)

IPEC Unit 3 - This item was closed during the October Closed 2014 NRC Audit Visit.

IPEC-048 IPEC Unit 2 - Updated response available on the Review ready ePortal IPEC 049 This item was closed following the October 2014 NRC Closed Audit Visit as documented in Reference 7.

This item was closed following the October 2014 NRC Closed Audit Visit as documented in Reference 7 This item was closed during the October 2014 NRC Closed Audit Visit IPEC-049d This item was closed following the October 2014 NRC Closed

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 19 of 21 Audit Status Completion or Questions Target Date Audit Visit as documented in Reference 7.

This item was closed during the October 2014 NRC Closed IPEC-049eAudit Visit.

IPE-09fThis item was closed during the October 2014 NRC Closed Audit Visit.

This item was closed during the October 2014 NRC Closed Audit Visit.

This item was closed during the October 2014 NRC Closed IPEC-049h Audit Visit.

IPEC-049i This item was closed during the October 2014 NRC Closed Audit Visit.

IPEC-050 Updated response available on the ePortal (associated Review ready with ISE Confirmatory Item 3.2.1.8.A)

IPEC-051 Updated response available on the ePortal (Unit 3 Review ready Open Item from the October 2014 NRC Audit Visit.)

• Closed indicates that Entergy's response is complete.

7 Potential Interim Staff Evaluation Impacts The following items indicate a change and/or update to the items identified in this section during the 2nd Six-Month Status Report.

1. ISE/TER Section 3.2.1.6, Page 32, the TER states "RCS boration is required for shutdown margin at 23.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />." The current analysis indicates that time for boration (beyond that provided by SI Accumulators) is 20.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for IPEC Unit 2 and 22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for IPEC Unit 3.

2. ISE/TER Section 3.2.1.9, Page 35, the TER states "This pump will provide core make-up such that a limited period of two phase natural circulation cooling occurs...." Based on the PWROG-14027 methodology, the current strategy for IPEC will prevent reflux cooling from occurring by initiating RCS makeup prior to 11.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for IP2 and 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> for IP3.

3. ISE/TER Section 3.2.4.3, Page 40, the TER states "...the licensee did not adequately address heat tracing." IP-CALC-13-00058 addresses the issue of heat tracing for IPEC Unit 3. Any required heat tracing would be restored with the Phase 2 diesels. . Calculation IP-CALC-14-00043 addresses the issue of heat tracing for IPEC Unit 2. The results determined that the tanks are relatively immune to freezing. Power to heaters and tank connection heat tracing will also be restored when the Phase 2 FLEX Diesel Generator is connected to the buses if the BDBEE requires it.

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 20 of 21 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Entergy letter to NRC (NL-1 3-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

3. Entergy letter to NRC (NL-13-110), Indian Point Energy Center's First Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2013

4. NRC letter to Entergy, Indian Point Nuclear Generating Unit Nos. 2 and 3 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0744 and MF0745), dated January 24, 2014

5. Entergy letter to NRC (NL-14-110), Indian Point Energy Center's Third Six-Month Status Report for the Implementation of Order EA-12-049 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0744 and MF0745), dated August 27, 2014 (ML14251A227).

6. Indian Point Nuclear Generating Unit Nos. 2 and 3- Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies AND Reliable Spent Fuel Instrumentation Related To Orders EA-12-049 and EA-12-051 (TAC NOS.

MF0744, MF0745, MF07371 AND MF0738), dated September 30, 2014 (ML14269A384)

7. Indian Point Nuclear Generating Unit Nos. 2 and 3 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA 12-049 and EA 12-051 (TAC Nos.

MF0744, MF0745, MF0737 and MF0738), dated December 9, 2014 (ML14335A642)

8. Entergy letter to NRC (NL-1 5-012), Entergy's Request for Relaxation from NRC Order EA-12-049, "Order Modifying licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC No.

MF0745) Indian Point Unit Number 3, dated January 28, 2015.

9. Westinghouse Report PWROG-14015-P, Rev. 1, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power, September 19, 2014.

NL-15-025 Dockets 50-247 and 50-286 Attachment Page 21 of 21

10. Westinghouse Report PWROG-142027-PRev 2, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power Task 3, October, 2014.